Dismissing the appeal of the Revenue the Court held that   the assessee and  Pawansut Trading Co Pvt Ltd. were entities covered under sub-section (3) of section 13 . However the Assessing Officer never examined whether the transactions between the assessee and the company were at arm’s length. He merely referred to statutory provisions and without further discussion came to the conclusion that disallowance had to be made. The Commissioner (Appeals) not only criticised this approach of the Assessing Officer but also independently examined whether the transaction was at arm’s length. It was found that the rate paid to the related person was the same as paid to the unrelated party. The Tribunal confirmed this view and correctly so. Order of Tribunal affirmed .   (AY. 2012-13)